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Subject: Re: [DCHAS-L] Required Training?

Date: Dec 12, 2018 16:34 UTC

Author: Meschewski, Brian D <bmesche2**At_Symbol_Here**ILLINOIS.EDU>

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Subject: Re: [DCHAS-L] Required Training?

Date: Dec 13, 2018 02:42 UTC

Author: James Kaufman <jim**At_Symbol_Here**LABSAFETY.ORG>

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From: Denise Beautreau <deb313**At_Symbol_Here**LEHIGH.EDU>

Subject: Re: [DCHAS-L] Required Training?

Date: Dec 12, 2018 17:14 UTC

Reply-To: ACS Division of Chemical Health and Safety

In-Reply-To: Re: [DCHAS-L] Required Training?

Demystify: 

Ruth Ann,
I have been a lab coordinator/manager and an instructor in for my entire career. The following includes the training I have received as well as my two cents:

1. I have been trained on the OSHA General Industry Standard, OSHA Lab Standard (as mentioned by Brian Meschewski) as well as because of the nature of my responsibilities I have been trained in Hazardous Waste Operations Supervising, DOT waste transport rules, Hazardous Waste Management as per The Resource Conservation and Recovery Act (RCRA) and some others.

2. The most important thing is to know what the persons expectations in their role and responsibilities are. This will be the determining factor in what type of training they are required to receive, not only based on OSHA regulations, but other federal and state regulatory agencies as well.

3. In my experience, faculty do not get exempt from any training requirements at the federal level, and I would guess neither at the state level. The only time I have seem an exemption based on having a terminal degree was in NYC for the certificate of fitness requirement, which would not apply to you in Texas in any case. I echo everything mentioned by Brian Meschewski and suggest meeting with your EH&S director or coordinator to see if any training has been completed by the lab coordinator and your faculty and if not what they can help you offer them.

Regards,

Denise

On Wed, Dec 12, 2018 at 11:38 AM Meschewski, Brian D <bmesche2**At_Symbol_Here**illinois.edu> wrote:

Hi,

Here is my two cents. I would consider the lab coordinator to fall under the OSHA Lab Standard, due to the type of work and the scale of the work they are doing.

*1. Is there any OSHA-required training for chemistry lab coordinators who work with chemicals in an academic setting, preparing labs, helping supervise labs, and preparing chemical waste for disposal companies?

What does your Chemical Hygiene Plan say? If an employee is working with chemicals on the laboratory scale (preparing solutions for a lab class for example), how is the employer ensuring their CHP includes provisions for the necessary employee information and training dictated by the OSHA Lab Standard? Part of this training includes knowledge of the hazards of the chemicals in their work area, PPE requirements, and emergency procedures. OSHA does not point to a specific training, but the employer is responsible for providing training. The waste question might require more info, are they the ones doing the shipping? RCRA and DOT come into play for sure.

*2. If so, what is required?

I agree that this depends on what they are working with, and what they are doing with it.

*3. Are faculty, based on their degrees in Chemistry, exempted from any such requirements?

Simply put, no.

Adding in my opinion, based on my relatively young career, I can say (anecdotally) that the type of degree, certifications, years of experience, or title does not necessarily mean that individual knows how to work safely. It can be a good indicator that they are knowledgeable about safe work practices, but there is no guarantee. All it takes is someone to underestimate risk once. And with as fast as research changes, new materials can be introduced regularly, or existing materials can be used in a new way.

Taking it a step further on the research side, the PI will likely have a whole team of young researchers (grad students, post docs, technicians, undergrads, etc) they are responsible for, engaged in a wide variety of research with materials the PI may not have direct experience working with themselves. At worst, training will be a minor inconvenience, and will be a reminder that there are regulations out there that they need to comply with. An experienced researcher may not even think about the hazards or associated risk anymore (and how to manage it), but their new students will not have that knowledge or experience. This reminder can help them help their staff.

Like I said, my two cents, but hopefully this helps.

Brian Meschewski

Research Safety Professional

Division of Research Safety

University of Illinois at Urbana-Champaign

(217)333-2423

bmesche2**At_Symbol_Here**illinois.edu